Huge Number of Comments Filed Over Proposed Debt Collection Rule, All Containing Same Typo

There has been a significant spike in the number of comments filed sharing opinions in the Notice of Proposed Rulemaking related to debt collection practices from the Consumer Financial Protection Bureau.

About 800 new comments have come in during the past 24 hours, bringing the total number of comments to 892. And if you want proof that many of them are form letters, submitted by consumers likely at the behest of consumer advocates, there is some pretty damning evidence: many of them have the same typo in them.

There are a couple of different templates that it looks like consumers had the chance to choose from, and 545 of the comments that were filed yesterday have the same mistake in them. It’s not a big deal, but it does offer some proof that the consumers did not come up with the comments on their own.

Many of the comments that were filed look exactly like this:

The Consumer Financial Protection Bureau (CFPB) was created to protect consumersespecially vulnerable consumers. 

Then why does the new debt collection proposal give debt collectors even more ways to harass and abuse consumers? It allows up to seven attempted calls per debt, per week. Two attempts per week would be more reasonable. 

The proposal also would allow unlimited texts, emails and direct messages without consent. Let consumers choose how they want to be contacted about a debt, with no electronic communications allowed without prior, express permission from the consumer.

Please create a debt collection rule that protects consumers from debt collector harassment!

The lack of a space between consumers and especially in the first sentence is kind of a dead giveaway that there was not a lot of unique, individual thought put into the comments. Especially since it’s unlikely that 545 different consumers all made the same mistake. What’s more likely is that the consumers did not proofread the comment after copying it and pasting it from whatever advocacy asked them to submit the “comment.”

Another very common comment that came in yesterday looked like this:

The Consumer Financial Protection Bureau (CFPB) was created to help, not harm, consumersespecially vulnerable consumers who are being harassed by abusive debt collectors. So why does the CFPBs proposed debt collection rule permit debt collectors more ways to harass and abuse consumers?

The proposed rule:

– Allows too many callsup to seven attempted calls per debt, per week! Instead, the rule should allow one conversation a week and two attempts per consumer, not per debt. 

– Allows unlimited texts, emails and direct messages without consent! Instead, consumers should choose how they want to be contacted about a debt, and no electronic communication should be allowed without prior consent. Collectors should be limited to one contact per weekper consumer, not per debt. 

– Protects deceptive practices by collection attorneys! Instead, the rule must require that collection attorneys review original account-level documentation of the debt to ensure they are collecting the right amount from the right person.

– Allows for collection of “zombie” debt! Instead, the rule should fully ban collection of debts that are too old to sue over. 

– Permits consumer privacy violations! The rule would allow limited content voicemail, email and text messages, which could be heard or seen by others. Instead, consumer privacy should be prioritized in all messages.

I urge the CFPB to create a fair debt collection rule, not make it easier for debt collectors and their lawyers to harass and abuse consumers!

While more detailed, it still had the same typo in the first sentence.

While the typo allows us to identify that the comments are not likely coming in unsolicited, they do represent a huge influx of requests for the CFPB to undo some of the changes it has proposed. And, to date, there have only been a handful of comments filed by those on the industry side of the transaction.